Legal Compliance
Last updated: Mar 19, 2026
Basecomp is building the most legally compliant and transparent prize competition platform in the UK. This page explains the regulatory framework, how our platform supports compliance, and what we require from every Merchant.
Our Role
Basecomp Ltd is a software company. We provide technology tools that enable businesses to create and manage prize competitions and promotional draws. We are not the promoter or operator of any competition on the platform. Each competition is organised and run exclusively by the Merchant whose storefront hosts it.
This is not simply a contractual position — it reflects how UK law operates. The Gambling Act 2005 places legal responsibility for the proper conduct of a competition on the Promoter (the Merchant). Basecomp's obligations are those of a responsible software provider: enforcing platform rules, maintaining technical integrity, and refusing service to operators who act unlawfully.
UK Legal Framework for Prize Competitions
Under the Gambling Act 2005, a lottery is defined as an arrangement where participants pay for the chance to win a prize, with outcomes determined entirely by chance. Running an unlicensed lottery in the UK is a criminal offence.
Prize competitions on Basecomp must fall clearly outside this definition. There are two lawful models:
Model 1 — Skill-Based Competitions
A competition is lawful where success genuinely requires the exercise of skill, knowledge, or judgement that would either deter a significant proportion of potential entrants from participating, or prevent a significant proportion of entrants from receiving a prize. The skill element must be substantive — not trivial, not easily searchable online, and not a formality.
Examples of compliant skill questions include multi-step mathematical problems, specific knowledge questions within a defined domain, or creative submissions judged on merit by an independent panel.
Model 2 — Free Entry Route (Alternative Method of Entry)
A paid-ticket competition is lawful where there is a genuine free Alternative Method of Entry (AMOE) that is:
- Clearly visible and prominently signposted on every competition page
- Genuinely free — no purchase, subscription, premium-rate charge, or commercial transaction required
- Equally accessible to all eligible entrants, including those without internet access (typically a postal route)
- Processed on genuinely equal terms — free entries must have the same chance of winning as paid entries
Basecomp's platform includes built-in support for configuring a compliant postal free entry route on every competition.
Merchant Obligations
Every Merchant using Basecomp agrees, as a condition of access to the platform, to:
- Structure every competition as either skill-based or with a genuine, compliant free entry route
- Publish complete, accurate terms and conditions for each competition before ticket sales open
- Clearly state the total ticket quantity, ticket price, draw date, and prize details
- Conduct draws on the announced date, or notify entrants promptly if the date changes
- Publish draw results transparently and publicly
- Fulfil prizes to winners promptly, as described in the competition terms
- Not misrepresent prize values, retail prices, or odds
- Operate age verification — all competitions on Basecomp are for participants aged 18 and over
- Comply with all applicable consumer protection legislation, including distance selling regulations
We monitor for violations and reserve the right to suspend or terminate access to any Merchant whose competitions are, in our reasonable judgement, structured unlawfully, run deceptively, or likely to cause harm to entrants.
FairLock — Cryptographic Draw Transparency
Beyond legal compliance, Basecomp has built a proprietary cryptographic commitment system — FairLock — that makes draw manipulation mathematically impossible, and allows anyone to independently verify the integrity of every draw.
FairLock works in four phases:
- Pre-commitment — Before any tickets are sold, the system generates winning positions using a cryptographically secure random number generator and publishes a SHA-256 hash of those positions. The positions themselves are encrypted and locked. This hash is public and timestamped, proving that winning positions were determined before the first ticket was sold.
- Ticket sales — Customers purchase tickets sequentially. Winning positions remain encrypted throughout. Instant wins are detected via a fast HMAC hash lookup — no position needs to be decrypted during the sale period.
- Draw — On draw day, the winning positions are decrypted and winners identified. The full proof — including the original positions, salt, and hash — is published publicly on the competition page.
- Independent verification — Anyone can take the published data and independently recalculate the SHA-256 hash using any standard SHA-256 tool. If the calculated hash matches the pre-commitment hash, it proves the winning positions were not changed after commitment. You do not need to trust Basecomp — you can verify it yourself.
FairLock means that every draw on Basecomp carries a level of provable transparency that no manual or unverified draw process can match. We believe this is the future standard for the industry.
Enforcement
If you believe a competition on the Basecomp platform is being run unlawfully, deceptively, or in breach of these requirements, please report it to us at [email protected]. We investigate all credible reports and will take appropriate action, including suspension of the relevant store, referral to consumer protection authorities, or — where warranted — referral to the Gambling Commission or Action Fraud.
Regulatory Outlook
The UK prize competition sector has operated in a regulatory grey area, but increased government scrutiny and public interest in consumer protection are driving change. Basecomp is actively engaged with these developments and designed from the ground up to meet — and exceed — any emerging standards.
Our goal is straightforward: to be the platform that operators choose when they want to do this properly, and the platform that regulators point to as the benchmark for how it should be done.
This page will be updated as the regulatory landscape evolves. If you have questions about compliance for a specific competition structure, contact us at [email protected].